Download - Compliance Basics Presentation
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Nick Merkin11845 W Olympic Blvd., Suite 1250
Los Angeles, CA 90064
310.996.8950
www.compliagent.com
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Seven Elements of a
Compliance Program
WRITTEN COMPLIANCE POLICIES AND PROCEDURES
DESIGNATED COMPLIANCE
PROFESSIONALS
EFFECTIVE TRAINING OF ALL
STAFF
EFFECTIVE COMMUNICATION
PREVENTATIVE AUDITING AND MONITORING
ENFORCEMENT OF STANDARDS
PROMPT RESPONSE TO POTENTIAL COMPLIANCE VIOLATIONS
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The Structure of our Programming...
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Program
Assessment
and
Development
of a Tailored
Compliance
Plan…
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Program Assessment and Development
of a Tailored Compliance Plan
Program Assessment
• Conduct initial assessment of
compliance programming already in
place.
• Identify areas for improvement and
risk concern.
• Presentation of findings through
confidential memoranda and
discussions with governing board and
senior management.
Compliance Plan
• Development of strategic compliance
plan narrowly-tailored to specific
client’s business and regulatory needs.
• Continuous monitoring and updating
of compliance plan to reflect
emerging risk areas and regulatory
developments.
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Education and
Communication
of Culture of
Compliance…
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Quarterly Compliance Survey
• Issue Compliance Survey to key Facility employees to encourage reporting of actual or potential compliance violations
• Investigation by Compliagent of any reported issues
• Outcome of investigations are reported to the Facility’s Governing Board and monitored by Compliagent for effective resolution as indicated
Update to Compliance Plan
• Annual review of the Compliance Plan (See Exhibit A)• Distribute Compliance Plan to facilities on an annual basis• All Facility employees receive a copy of the Compliance Plan
Participation in Policy Committee
• Assist with the development of a monthly policy review agenda• Provide regulatory and clinical guidance for policy development
Monthly Facility Updates
• Monthly newsletter and additional guidance statements concerning regulatory issues as warranted
• Quarterly distribution of Dashboard reporting Facility specific compliance metrics (See Exhibit B)
• Issue policy updates from Policy Committee
Education and
Communication of Standards
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Ongoing Compliance Support
and Guidance
• Each Facility is assigned a
designated consultant to provide
ongoing support with the
maintenance of the Compliance
Program
• Compliagent consultants are
available to the facilities to
provide guidance with regard to
operational and clinical
regulatory issues as needed
Quarterly Training
• Mandatory Annual Training: Compliance
Program and HIPAA
• Additional training topics are selected by
Compliagent based upon client request,
observed need, and regulatory
enforcement priorities (See Exhibit C)
• Trainings are conducted both on-site
and via webinar
• Compliagent provides training materials
to Director of Staff Development for
mandatory in-services to all staff
Education and Communication
of Standards (Continued)
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Risk Management…
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Risk Management
Compliance Complaint
Investigation
• Develop investigation plan in coordination with Facility Compliance Officer
• Investigation may include interviews of residents and/or employees, resident specific record review, or audit of multiple records
• Investigational findings and recommendations are communicated to the Compliance Officer, Administrator and Governing Board (See Exhibit D)
Hosting of Compliance Hotline
• Hotline posters provided to each Facility• Compliance Hotline is a voicemail box that permits
reporting 24/7 and allows callers to remain anonymous• Hotline calls are reported to the Compliance Officer
and Administrator, unless a conflict of interest exists
Risk Assessment
• The Risk Assessment is revised annually base don regulatory enforcement priorities
• Facilities complete the Risk Assessment on an annual basis
• The Risk assessment using scoring based upon the response to determine the prioritization of risk management
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Risk Management (Continued)
Compliance Audits
• Client selects the audit area for the
Facility based on the information
provided in the Risk Assessment
• Audits include both operational and
clinical topics (See Exhibit C)
• Audit findings and recommendations are
communicated to the Compliance
Officer, Administrator and Governing
Board
Exclusion Screening
• Monthly exclusion screening performed
for all facility employees
• Any negative results are communicated
to Compliagent Consultants and the
facilities
• Compliagent consultants coordinate
with the Facility’s administrator to
address and resolve identified exclusions
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Monitoring and Reporting…
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Monitoring and Reporting
Monitoring of Compliance Action Plan
• Facility develops an action plan to
address risk area identified in the OIG’s
annual work plan
• Any corrective actions resulting from
hotline complaints or audits are also
added to the action plan
• Compliagent reviews the Facility’s action
plan no less than quarterly to ensure
effectiveness of the corrective actions
Governing Board Reports
• Compliagent will report all Compliance
Program activity from the preceding
quarter and provide updates on an
ongoing activities
• The Administrator reports on topics such
as survey results, compliant surveys, QAPI
activity, etc.
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Maintenance
and
Validation…
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Maintenance and Validation
Annual Compliance Program
Assessment
• Compliagent conducts an annual assessment to determine how effectively the Facility has implemented each of the OIG’s identified 7 elements of compliance
• Results are communicated to the Compliance Officer and Governing Board
Quarterly Compliance Program Dashboard
• Compliagent issues a Facility specific dashboard quarterly to capture the Facility’s progress and areas for improvement
• The information captured on the dashboard will vary but may include Risk Assessment scoring, Compliance Program Assessment scoring, hotline call volume, and quality measures
Annual Risk Profile Evaluation
Assessment
• Compliagent has developed a tool for the categorization of risk to identify priority facilities
• The data used includes survey deficiencies, quality measure data, staff turnover, star rating, etc.
• Compliagent updates the used to calculate the risk profile on an annual basis
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The Business
Benefits of
Independent
Compliance
Programming …
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Access to Multiple Professionals With Varied
Specialties Through a Single Point of Contact…
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Single Point of Contact
We bring to bear a higher level of
professional firepower to a compliance
matter at a lower cost.
Access a network of qualified compliance
professionals with different specializations
through a “one-stop shop” approach…
Even Larger Healthcare Organizations Need Help• May only have a handful of experienced
compliance professionals with a narrow
range of expertise on staff.
Evaluating of Resources• Only enough room and resources for so
many senior compliance personnel within
one entity.
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Lower Upfront Investment…
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Lower Upfront Cost
Even for organizations that are committed to building
out a more extensive internal compliance
department, it usually makes financial sense to begin
with a combination of insourced and outsourced
expertise.
The initial investment in hiring qualified and
experienced healthcare compliance
professionals is high…
Building Compliance Infrastructure On Your Own is
Expensive• Hiring even a single compliance specialist and
assistant may cost a healthcare organization
hundreds of thousands of dollars a year.
Outsourcing Saves You Money• Upfront expenditures involved in outsourcing an
entity’s compliance function are much lower and
involves a much smaller commitment to a scope of
work that is narrowly defined and leanly priced in a
detailed retention agreement.
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Quicker
Adaptation
to Regulatory
Changes…
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Regulatory Adaptation
We a unique, multi-faceted perspective, gained from
advising a variety of organizations, to develop “best
practices” with an eye towards your business goals.
Regulation Requirements are Going
to Get Worse…
Internal Change is Hard
• Implementing organizational change internally
can be cumbersome and a drain on
resources.
Outsourcing Makes it Easier
• We focus specifically on the nuances of legal
change and interpretation, are better suited
than an internal corporate compliance
department to monitor and react swiftly to
changing laws and regulations.
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More Flexible
Use of
Compliance
Resources…
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Compliance ResourcesCompliance 101
We have specialists in all these areas, so we
can more nimbly address your evolving
compliance concerns.
We give you the ability to pick and choose from a
menu of compliance options at any given time…
Specialized Resourcing
• We are able to tailor our resources based on
an organization’s most recent compliance
plan or risk assessment
• Ex. HIPAA Training or Employee Screening
Flexibility
• We can follow new, strict budgets that will
address any more pressing compliance needs
as the organization grows
• Resources are not locked-in to any
particular need
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Third-Party Objectivity…
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We’ve earned more credibility and success in
reaching agreements and compromises with the
government on behalf of their own clients.
Third-Party Objectivity
Third-Party Objectivity is Two-Fold…
Internal
• Difficult for employees to be completely
objective about the strengths and, especially,
the weaknesses in the organization
• Fear of reprisal and fear of judgment is a high
concern for employees
External
• Third-party conclusions may be viewed as
more independent
• Outsourced compliance specialist findings
carry greater weight
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We Guide
Providers and
Help Them
Develop Self-
Perpetuating,
Scalable
Infrastructure…
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Improving the Bottom Line…
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Nick Merkin11845 W Olympic Blvd., Suite 1250
Los Angeles, CA 90064
310.996.8950
www.compliagent.com
Thank You.
Questions?